EPR in Poland 2026: BDO, packaging, WEEE and batteries — what sellers need to know

What is EPR in Poland?

EPR stands for Extended Producer Responsibility. In practice, a company placing certain products or packaged products on the Polish market may be responsible not only for the sale, but also for financing collection, recycling or recovery, keeping records and reporting data to the authorities.

There is no single Polish EPR number covering everything. The scope depends on the product and the company's role in the supply chain. The system covers packaging, electrical and electronic equipment, batteries and accumulators, as well as selected products such as tyres, oils and certain single-use plastics. Its central register is BDO — the database on products, packaging and waste management.

Who must register in BDO?

The decisive question is not where the company is established, but who places the product or packaging on the Polish market. Duties may apply to a Polish manufacturer, a non-EU importer, an intra-EU acquirer, a brand owner, or a foreign online or marketplace seller shipping directly to Polish customers.

Using Amazon, Allegro, eBay, Kaufland, Temu or a Shopify store does not by itself determine who is responsible. The actual sales and logistics model must be assessed.

Example: an online store sells electronics to Poland

Consider a German company selling an LED lamp with an integrated battery directly to a Polish consumer. The product arrives in a cardboard box with protective plastic film, and the store adds a shipping carton.

• WEEE — because electrical equipment is being sold
• Batteries — because the product contains a battery
• Product packaging — the box and protective film
• Shipping packaging — the additional carton used to fulfil the order

BDO registration is only the beginning

BDO is the state system used to register businesses and submit reports on products, packaging and waste. Once registered, a company receives a BDO number, but this does not mean every obligation has been fulfilled.

The registration must cover the correct activities and streams. A company dealing with packaging, electronics and batteries may need entries for several separate areas.

How much does BDO registration cost in 2026?

The annual fee is the same and, where applicable, is generally due by the end of February. No additional annual fee is paid in the year in which the registration fee was paid.

The BDO fee is not the full cost of EPR. Depending on the stream, costs may also include a recovery organisation, recycling, educational campaigns, collection obligations or product fees.

• Micro-enterprise: PLN 200
• Other businesses: PLN 800

Packaging EPR in Poland

Reporting can cover product, grouped, transport and e-commerce shipping packaging. Knowing the total parcel weight is not enough: data must be split into materials such as paper and cardboard, plastics, glass, steel, aluminium or wood.

If one shipment contains 180 g of cardboard, 12 g of film and 25 g of paper filling, each material must be recorded separately. Across thousands of orders, manual spreadsheet calculations quickly become unmanageable.

Does a small amount of packaging exempt you from BDO?

Poland has de minimis aid mechanisms for businesses placing certain small quantities of packaging on the market, including a threshold of 1 Mg — one tonne — per year. It should not be treated as a general EPR exemption.

Relief from selected financial duties does not necessarily remove registration, record-keeping or reporting duties, and using de minimis aid requires meeting formal conditions.

What data should you collect?

Good EPR reporting starts long before 15 March. Sales data should be linked with product and packaging records.

• Product or SKU identification and sales market
• Number of units sold
• Packaging components and the material of each component
• Weight of each component
• The correct EPR category, plus stream-specific WEEE and battery data

EPR reporting deadline in Poland

The annual report on products, packaging and resulting waste is submitted electronically through BDO. The standard deadline is 15 March for the previous calendar year.

Submitting the report does not always end the process. Separate deadlines may apply to fees, recovery organisation documents and duties specific to each stream.

WEEE in Poland

Companies placing electrical or electronic equipment on the Polish market must separately assess obligations under waste electrical equipment rules. The key questions are whether the product meets the definition of electrical or electronic equipment and who is placing it on the market.

Reporting may require assigning equipment to the correct category and recording its weight. Selling small devices online does not automatically create an exemption.

Batteries are a separate EPR stream

A battery integrated into a device does not disappear from a compliance perspective. Batteries and accumulators form a separate EPR stream, so the same SKU may appear in WEEE, battery and packaging data.

EU Regulation 2023/1542 on batteries and waste batteries is becoming increasingly important, while Poland adapts its national rules. During the transition, verify the current procedure for the specific sales model and battery type.

EPR and PPWR are not the same

Regulation (EU) 2025/40 on packaging and packaging waste applies from 12 August 2026. It does not make national EPR obligations disappear.

PPWR concerns the conformity of the packaging itself, including technical documentation, declarations of conformity, design and substances, followed later by recyclability and labelling requirements. Polish EPR concerns registration, records, reporting and financing obligations for packaging placed on the Polish market. These are two different compliance layers for the same box, bottle or mailer.

What should a foreign seller do before selling in Poland?

• Identify which products are covered and who places them on the Polish market
• Assess packaging, WEEE and batteries separately
• Confirm the required BDO registration scopes
• Build SKU-level product and packaging data
• Connect that data with actual sales to Poland before calculating volumes and reports

How EPRPilot helps with EPR in Poland

The hardest part of EPR is rarely submitting one form. The challenge begins when a company sells hundreds or thousands of SKUs in several markets, each requiring a different data set.

EPRPilot combines product, sales and compliance data in one place. It assigns products to EPR streams, stores packaging information, monitors sales volumes and deadlines, and prepares data for national reports. Polish BDO becomes part of one EU-wide EPR process instead of a separate spreadsheet rebuilt every year.

The key conclusion

Do not ask only: ‘Do I have a BDO number?’ Ask instead: ‘Do I know which products and packaging I am responsible for in Poland, and can I reproduce the data in my report?’

A registration number is only the beginning. Real compliance starts with accurate data. EPRPilot helps manage packaging, WEEE and battery obligations across European markets — from product and sales data to deadlines and reporting.